Below
we have listed the top seven topics that we receive continual queries
about.
Dynamic
Testing.
Dynamic
testing verifies the execution flow of software, including decision paths ,
inputs, and outputs. Dynamic testing involves creating
test cases,
test vectors and oracles, and executing the
software against these tests. The results are then compared with
expected or
known correct behavior of
the
software. Because the number of execution paths and
conditions
increases exponentially with the number of lines of code, testing for
all
possible execution traces and conditions for the software is impossible.
Static
Analysis.
Code inspections and
testing can reduce
coding errors; however, experience has shown that the process needs to
be
complemented with other methods .
One such method is static analysis.
This somewhat new method
largely automates the software
verification process. The
technique attempts to identify errors in
the code, but does not
necessarily prove their absence. Static analysis is
used to identify
potential and actual defects in source code.
Abstract
Interpretation
Verification.
A code verification solution
that includes abstract interpretation can
be
instrumental in assuring software safety and a good quality process.
It is a sound verification process that
enables the
achievement of high integrity in embedded devices. Regulatory bodies such
as the
pharmaceutical regulators.
There
is no
regulatory requirement to re-validate a process as long as that process
operates in a state of GMP control
and no changes have been made to
the process
or output product,
the process does
not have to be revalidated. Whether the process is operating in a state
of
control is determined by analyzing day-to-day process control data and
any
finished device testing data for conformance with specifications and
for
variability.
When
equipment is moved to a new location, installation and operation should
be
re-qualified. By comparing data from the original installation and
operation
qualification (IQ and OQ)
and the re-qualification, the manufacturer can
determine whether there have been any changes in equipment performance as
a result of the move. Changes in equipment performance should
be evaluated to determine whether it is necessary to revalidate the
process.
Part
820.75 of
the QS regulation
requires that validated processes be monitored and controlled so that
when
changes or process deviations occur, a manufacturer will
know to review and
evaluate the process and perform revalidation when
appropriate. 21
CFR 820.75(c ) requires you to have documented procedures in
place for evaluating; when revalidation is required.
Recent
research has highlighted that in the pharmaceutical and bio-medical
industry,
thirty two percent of all equipment procurements are
unsatisfactory. The
major problem has been identified as companies not specifying in
sufficient
detail and or accuracy, what their actual
needs are. The lack of a quality company approved User
Requirements
Specification (URS) , leads
to many
companies having to resort to otherwise un-necessary and costly retrospective actions
in modifying the equipment or producing unspecified documentation or
engineering drawings, post procurement. These extraneous GMP
requirements often
cost more than the equipment.
Combination IQ/OQ/PQ
Protocol.
Combination
IQ/OQ/PQ
Protocol.
This
combination protocol has been produced in response to several hundred
reader
suggestions we received in our ‘Suggestions
Section’. It has been carefully
designed to make it the preferred choice for Process and Laboratory
stand-alone
equipment. It is an interactive, fully detailed, sixty three page
protocol that
runs to approximately seven thousand words. It is presented in 'MS
Word' to
facilitate ease of final editing by the end user. It has become a very
popular
document.
Combined IQ/OQ/PQ Equipment Protocol (Issue-2). -- $159.00
Combined IQ-OQ-PQ Computer Protocol (Issue 3) -- $159.00
Software Validation SOP (Issue-2) -- $22.00
Software Validation Master Plan (issue-2) -- $115.00
Software Validation Risk Assessment (Issue 2) -- $125.00
Software User Requirements Specification. (Issue 2) -- $115.00
Software Validation Plan (Issue 2) -- $89.00
Software Design Qualification. (Issue 2) -- $89.00
Software Installation Qualification. (Issue 2) -- $89.00
Software Operational Qualification. (Issue 2) -- $89.00
Software Performance Qualification. (Issue 2) -- $89.00
Software Validation Package (Issue 1) -- $699.00
A recent warning letter demonstrates just how few companies use a Gap Analysis to validate that they are compliant. CAPA discrepancies continue to be the biggest single source of problems. However the daddy of them all recently has been a well known company that had carefully documented the levels of experience and educational standards required for various GMP sensitive roles (In accordance with GMP), only for the FDA to find the persons in these jobs were not qualified properly. (click here to read)
Do use a Gap Analysis and avoid these embarrassing events. Gap Analysis Tool (Issue 2.) -- $115.00
Validation Risk Assessment (Issue10.) -- $125.00
This popular Validation Risk Assessment (VRA) has now been edited and enlarged to include Part 11 assessment tables for you to use in classifying which of your predicate records require to be stored in compliance with 21 Part 11, and which do not. It also includes an Excel spreadsheet to allow you to establish a permanent record of all such judgements, as is now mandated by the regulatory authorities.
|